UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
__________________________________________)
FEDERAL TRADE COMMISSION, ))
Plaintiff, ))
v. ) Civil No.
)
CITIGROUP INC., CITIFINANCIAL CREDIT )
COMPANY, ASSOCIATES FIRST CAPITAL )
CORPORATION, and ASSOCIATES )
CORPORATION OF NORTH AMERICA, )
Delaware corporations, ))
Defendants. )
__________________________________________)
COMPLAINT FOR PERMANENT INJUNCTION
AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("Commission"), by its undersigned attorneys,
alleges as follows:
1. This is an action under Sections 5(a), 13(b), and 16(a) of the Federal Trade
Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a), 53(b), and 56(a), Section 108(c) of the Truth
in Lending Act ("TILA"), 15 U.S.C. § 1607(c), Section 704(c) of the Equal Credit Opportunity
Act ("ECOA"), 15 U.S.C. § 1691c(c), and Section 621(a) of the Fair Credit Reporting Act
("FCRA"), 15 U.S.C. § 1681s(a), to secure permanent injunctive relief and other equitable relief,
1
including rescission, restitution, reformation, and disgorgement, against defendants for engaging
in unfair or deceptive acts or practices in violation of Section 5(a) of the FTC Act, as amended,
15 U.S.C. § 45(a), acts or practices in violation of the TILA, 15 U.S.C. §§ 1601-1666j, as
SNIPPETS:
UNITED STATES DISTRICT COURT
COMPLAINT FOR PERMANENT INJUNCTION
Plaintiff, the Federal Trade Commission, by its undersigned attorneys,
Commission Act, 15 U.S.C. §§ 45, 53, and 56, Section 108of the Truth
Act, 15 U.S.C. § 1691c, and Section 621of the Fair Credit Reporting Act
, 15 U.S.C. § 1681s, to secure permanent injunctive relief and other equitable relief,
including rescission, restitution, reformation, and disgorgement, against defendants for
in unfair or deceptive acts or practices in violation of Section 5of the FTC Act, as amended,
practices in violation of the ECOA's implementing Regulation B, 12 C.F.R. § 202, as amended,
and acts or practices in violation of the FCRA, 15 U.S.C. § 1681a-1681u, as amended.
Government created and given statutory authority and responsibility by the FTC Act, as
FTC Act, 15 U.S.C. § 45, which prohibits unfair or deceptive acts or practices in or affecting
commerce, and the TILA, ECOA, and FCRA.
limited to, redress and disgorgement.
Associates"), offered finance products and services to consumers, including home equity loans,
The Associates disseminated advertisements to the public that promote consumer
subprime market, The Associates, like other subprime lenders, charged its customers prices
financed on the loan) charged to such customers.
and fees and to purchase high-cost credit insurance.
into a single debt consolidation loan, typically a home equity loan, a practice known as
consolidating the consumer's debts with an Associates loan,
include in a customer's monthly payment an escrow amount for property taxes and homeowner's
Closing costs can be a one time fee
and closing costs on home equity loans and included these costs in the consumer's loan
Plaintiff incorporates by reference all the foregoing paragraphs.
representation, as alleged in paragraph 40, was false or misleading.
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